Document 3Q3wJX2n0YMdJam7X8mo7b0O0

AEROSPACE] INDUSTRIES ASSOCIATION Impact of the Proposed EU REACH PFAS Restriction on the Aerospace and Defense Sector AIA Chemical Subcommittee September, 2023 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 l www.aia-aerospace.org Contents 1 General Comments 3 1.0 Introduction and Summary 3 1.1 Information on PFAS uses in the aerospace and defense sector 4 1.2 Risk of obsolescence and disruption of A&D supply chains 5 1.3 Difficulty identifying PFAS 5 1.4 Appropriateness of Regulating All PFAS Identically 7 1.5 Fluoropolymers Are of Low Concern 7 1.6 Uses and Sub-uses: 8 1.7 Alternatives and Substitution Timelines 14 1.8 Socio economic analysis (SEA) issues 17 1.9 Sectors 19 1.10 Emissions and Recycling in the End of Life Phase 20 1.11 Proposed derogations 20 1.12 Potential Derogations Marked for Reconsideration 21 2 Aerospace PFAS Use Examples 23 2.1 Fire Suppressing Agents 23 2.2 Hydraulic fluid 28 2.3 Coatings -- Organic finishes 30 2.4 Seals 37 2.5 Wires, Cables and Optical Fibers 39 2.6 Refrigerants 41 2.7 Solvents, Cleaners 42 2.8 Composite Processing Applications 44 Appendix A: GCCA White Paper 47 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 l www.aia-aerospace.org 1 General Comments 1.0 Introduction and Summary Founded in 1919, AIA is the premier trade association representing over 320 major aerospace and defense manufacturers and suppliers and more than 2.2 million employees. Among its members are the United States of America's leading manufacturers and suppliers of civil, military, and business aircraft, helicopters, unmanned aerial systems, missiles, military airborne, ground-based and naval systems, space systems, aircraft engines, material, and related components, equipment services, and information technology. AIA is pleased to provide the following comments on the proposed PFAS restriction. Both fluoropolymers (e.g., PTFE, PFA, PVDF, etc.) and non-polymeric PFAS are used in the Aerospace and Defense (A&D) industry in a wide variety of critical applications that are further detailed in this document. The properties of PFAS are commonly unmatched by other materials, and the products containing them are often required for the safe, reliable and effective operation, maintenance and repair of today's commercial and military aircraft and many other A&D products, including critical military equipment. Further, a review of other submissions from the A&D value chain in response to the proposed restriction also reveals a wide dependence on PFAS in developing products for the A&D industry, even for products that do not contain PFAS. Further, we conclude from our and suppliers' information that feasible alternatives are not currently available for most of those uses, and in many cases will not be available for the foreseeable future. In our industry, many uses of PFAS have been formally approved and certified for the functions and capabilities they provide. We also believe that proposal significantly underestimates the socioeconomic costs that the restriction will have on the REACH member states without significant revision. Finally, the A&D industry is very concerned about the continued availability of products and materials needed to manufacture and support industry products, and ensuring those products continue to meet the stringent product performance, safety and reliability requirements demanded by its customers and other stakeholders, including regulatory bodies. AIA proposes the following changes be made in the restriction proposal as justified by the information presented here: Derogations for PFAS In Section 1.8, we propose a derogation for all uses and sub-uses of PFAS chemicals for the aerospace and defense sector; The derogation should include technology readiness evaluations to determine whether alternatives are available for any uses and sub-uses and what appropriate adjustments should be made to the duration of the derogations. Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 l www.aia-aerospace.org Exemption/exclusion for fluoropolymers As explained in Section 1.5 we fully support removing or exempting fluoropolymers from the scope of the restriction; The derogation should include low molecular weight PFAS chemicals used for producing fluoropolymers. Chemical identifiers In Section 1.3, we strongly suggest that an explicit list of chemical identifiers (CAS numbers) be provided for the PFAS covered by the restriction. Repair as produced In Section 1.8, we support the repair as produced principle where products should be allowed to be repaired as originally designed and produced. 1.1 Information on PFAS uses in the aerospace and defense sector AIA wishes to highlight additional and complementary information about PFAS use in the A&D sector. Much of this information is found in comments submitted directly by other organizations. Where possible these comments are cited in Table 1 and elsewhere in this submission where they are specifically relevant. We also want to highlight comments submitted by Aerospace, Security and Defence Industries Association of Europe (ASD, Submission # 4419 and their follow-on submission), the US Chamber of Commerce (Submission # 6288), American Chamber of Commerce to the European Union (AmCham EU, Submission # 4584) and a white paper developed by International Aerospace Environmental Group (IAEG). IAEG commissioned a report this year to highlight the uses of PFAS within the A&D industry and illustrate the complexities facing this sector with regard to the identification and understanding of PFAS uses across the supply chain, and the challenges facing the industry in terms of finding substitutes to PFAS across this wide range of applications. Many members of AIA (and ASD) contributed data to the report. In particular, this report aims to: Highlight and map the key uses of PFAS within the A&D sector that are covered under the proposed restriction proposal (both in relation to 'transport' and other related sectors), as well as uses that are not explicitly discussed in the restriction proposal. Identify the 'critical' uses of PFAS in the A&D sector, where alternatives may not currently meet specific performance or safety standards. Illustrate the challenges in identifying if and where PFAS are used in specific products or components and the complexity of the A&D supply chain. The upcoming report will be found at the IAEG website at https://www.iaeg.com/workgroups/wg5/activities. Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 l www.aia-aerospace.org 1.2 Risk of obsolescence and disruption of A&D supply chains The potential for regulatory-driven obsolescence (even for exempted and derogated uses) is a real concern for companies in the A&D industry, with the result of significant socio-economic cost to the EU member states. As mentioned elsewhere, many organizations in the A&D supply chain have identified significant risks from the proposed restriction on their ability to continue to supply to the EU and global markets. Suppliers to the industry may make decisions to remove PFAS substances (including products made from those substances) from the market for various reasons. These can include compliance with anticipated regulations that have not yet entered into force, lack of continued marketability/profitability for PFAS-containing products or limiting their own risks and liabilities associated with continued production and/or processing of PFAS such as with 3M's recent decision to exit the market on all PFAS products.' While we recognize that these are decisions that individual companies may make, our concern is that such decisions may be made without full regard to the downstream impacts on customers that rely on these products. Ultimately, aerospace and defense suppliers and companies would be required to mitigate such cases of obsolescence in a manner that could include temporary stockpiling, reformulation, replacement with qualified materials, relocating work outside of the EU/EEA, redesigning, requalifying and recertifying end products. Further mitigation would not necessarily result in phasing out PFAS. In the simplest of cases companies may switch to a product from another supplier that may already be qualified. If there is not an existing qualified alternative, they may need to qualify an alternative from another source, and this may very well be another product that contains PFAS. In fact, it may be easier to qualify a PFAS-containing alternative, especially when it is the same PFAS chemical, because the products will have similar properties and demonstration of interchangeability will be less time consuming. Thus, given the choice between qualifying a PFAS vs. a non-PFAS candidate alternative, the PFAS option could be chosen to maintain business continuity. 1.3 Difficulty identifying PFAS While we are just beginning to understand our dependence on substances within the scope of the proposed restriction, tracing chemical substance content information and transparent communication of that information is extremely challenging. For "downstream" manufacturers of complex articles with global, multi-layered supply chains such as those in the A&D industry, this means tracing substance information through many levels of the supply chain, starting with parts manufacturers through to the complex assemblies used in our products. The A&D industry includes thousands of global subcomponent suppliers, including numerous small-to-medium sized companies. In order to determine the chemical composition of these subcomponents, the suppliers must be able to reliably collect and accurately report data on substances used in each specific subcomponent as well as in its manufacturing process at each level of the supply chain. This challenging situation is compounded by the fact that spare parts are routinely produced several years in advance of their use, where the precise understanding of their composition was not available at that time of their manufacture. Further, while process and tools to obtain and use composition data have been under development by the industry for several years, adoption in the global supply chain has not fully developed and significant gaps in such data remain. https://news.3m.com/2022-12-20-3M-to-Exit-PFAS-Ma nufacturing-bv-the-End-of-2025 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 l www.aia-aerospace.org Further, the presence of PFAS in chemical products has not been consistently covered by chemical information contained on safety data sheets (SDS) for materials used in the supply chain. In many cases, individual PFAS are still not widely recognized as hazardous, are present below applicable cut-off thresholds and/or are proprietary substances. If a PFAS is not explicitly listed in an SDS (which is common in our experience) with a commonly-recognized identifier (Chemical Abstract Series "CAS" Numbers are the most-commonly used numerical identifier to accurately identify substances worldwide) then the identification throughout the supply chain is extremely challenging, including where substances are processed into articles. If the lack of PFAS identification through the supply chain is not addressed on a global scale, then PFAS content reported through the supply chains for our products will always be incomplete. Factors that affect a company's ability to connect with and obligate members in global supply chains to collect information for a finished industry product include local regulatory requirements and industry best practices, contractual obligations and agreements between and among members in the supply chain, the number and locations of those members, the types of equipment (e.g., military or commercial), and time (e.g., the number of years in the data call, the amount of time to complete a data call). Supply chain members face challenges to reliably collect and accurately report composition data because of the typical complexity of the articles produced by the industry (e.g. aircraft), the availability of the information, and often limited use of product chemical content data for articles by actors in the supply chain. Stockpiled supplies and replacement parts (i.e., historical supply) add layers of complexity and complication given that supply chain partners regularly change and may no longer have contractual obligations to provide information, and/ or components, complex assemblies and finished articles may have changed chemical content over time. In practice some A&D companies report that it takes typically around 24-36 months after a substance has been added to the EU REACH Candidate List for data on those substances in industry hardware (articles) to be received from the majority of the global article supply chain. In the case of requests for PFAS to be declared at much lower levels (0.1% for the Candidate List vs. 25 parts per billion threshold in this restriction proposal), we anticipate that it will take much longer to obtain such information from the global supply chain. The large number of substances in scope of this proposal will further extend the time. In addition, if testing is identified as necessary to determine the PFAS content of articles, laboratory testing availability, capability, and capacity (and possibly costs) of suitable tests are also considerations that will lead to longer timeframes for compliance with proposed restriction limits. Further, basing a restriction on a definition and not explicitly-defined chemical identities (including CAS numbers) will make it extremely difficult for article manufacturers sourcing from many supply chains to understand their dependence on PFAS (including for PFAS in production equipment/ materials that don't appear in supplied products), as many suppliers may not be able to identify a PFAS even when it is reported in an article declaration or an SDS. This difficulty will be exacerbated for goods sourced from non-EU suppliers. The lack of PFAS identifiers will also make consistent enforceability nearly impossible, even though "enforceability" is a requirement of REACH Annex XV (under the section titled "Justification for Restrictions at Community Level") for justifying the need for an EU-wide restriction. Thus, we strongly suggest that an explicit, comprehensive list of chemical identifiers (CAS numbers) be provided for substances within the scope of the final restriction. 6 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 l www.aia-aerospace.org 1.4 Appropriateness of Regulating All PFAS Identically We agree with the many comments already submitted that the identical regulation of over 10,000 species of PFAS is inappropriate from both regulatory and risk management standpoints. As a class of substances, PFAS have extremely wide set of chemical properties and functionalities and environmental and human health impact profiles. As such, many PFAS do not meet the criteria that support restriction being the best option to manage risk. Further, we believe that many types of PFAS provide significant benefits to society at minimal risk and therefore should not be covered by the restriction. Certainly, regulatory responses for groups of PFAS exhibiting similar properties have been successfully used to control risks (e.g., the recent addition of perfluorohexane sulfonic acid (PFHxS), its salts and PFHxSrelated compounds to the EU POPs regulation), and we encourage that approach be continued in a riskinformed and prioritized fashion. Because of the broad and unprecedented proposed approach to restrict such a large and diverse group of chemicals with many critical uses, many derogations will need to be granted (even with limited existing data) for essential uses, often with only rough estimates of the time needed until replacements might be available. We see that these points have also been made by numerous other commenters and we concur with those comments. AIA is also very concerned with the implications that the proposed restriction might have on imports to the EU from the US and other EU trading partners. As indicated in this response, AIA (including through many A&D industry suppliers) has identified multitudes of instances where the use of PFAS is essential to the proper operation and support (maintenance and repair) of A&D products, with no alternatives that provide the same levels of effectiveness, safety, and reliability needed to properly conduct air travel, military missions and a wide variety of other socioeconomic functions supported by our industry. However, there are currently no consistent regulatory drivers across many trading partners and EU allies requiring the comprehensive identification of PFAS use; in fact, there are disagreements between countries and other entities as to what even constitutes a PFAS. As a result, efforts to identify PFAS uses have only just recently been initiated in the US and other regions and there is significant risk that critical uses have not have yet been fully identified. As a result, AIA is concerned that the envisioned restriction (if not appropriately and carefully amended) may create barriers to the free trade in commodities and materials where PFAS use is not fully characterized, including those that are essential for the proper functioning and security of EU society. AIA is also concerned that the proposed restriction of fluorinated gases under Annex XVII is creating confusion and concerns of "double regulation" for "F-gases" - hydrofluorocarbons (HFC), hydrofluoroethers (HFE) and hydrofluoroolefins (HFO), many that are currently essential and are needed for continued use under the HFC phase-down schedules agreed to in the Kigali Amendment to the Montreal Protocol. To prevent this situation and ensure consistent regulation, it is our recommendation that F-gases subject to other regulatory instruments (e.g., the EU F-Gas Regulation) be excluded from the scope of the proposed PFAS restriction. 1.5 Fluoropolymers Are of Low Concern Polymeric PFAS, generally referred to as fluorinated polymers, include fluoropolymers, perfluoropolyethers (PFPE), and side-chain fluorinated polymers (SCFP). Although fluoropolymers fit the PFAS structural definition, they have been shown to be thermally, biologically, and chemically stable; have very low water solubility and are considered to be nonmobile, nonbioavailable, and Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 l www.aia-aerospace.org nonbioaccumulative (Henry et al. 2018)2. In this study, four major fluoropolymers were demonstrated to meet the criteria as Polymers of Low Concern (PLC) as set by the Organisation for Economic Cooperation and Development (OECD). Following the analysis presented by Henry et al., 2018, 14 additional commercially manufactured fluoropolymers have recently been shown to also meet the PLC criteria (Korzeniowski et al. 2023)3. Taken together, these two studies covered -- 96% of the global fluoropolymers market and can be considered to be representative of the low environmental and toxicological concern posed by these materials. Considering this, and as described in the previous section, fluoropolymers generally meet the criteria as persistent but do not pose the toxicity risk warranting restriction. As a result, we fully support excluding fluoropolymers from the scope of the proposed restriction. Since fluoropolymers are produced from the polymerization of low molecular weight PFAS constituents, a derogation will also be required for the low molecular weight PFAS constituents required to produce fluoropolymers, with appropriate controls in place to minimize the impact of these low molecular weight PFAS constituents on the environment. 1.6 Uses and Sub-uses: AIA has compiled a list of PFAS uses and sub-uses from available sources including AIA member queries, IAEG WG5 data, information from other sectors and companies, literature searches, internal engineering records, safety data sheets, etc. As cautioned elsewhere, we are not confident at this stage that the list is comprehensive and as such should be considered indicative. Table 1 PFAS uses and sub-uses of the A&D sector identified by AIA." For each use, AIA has also broadly identified the type of PFAS (e.g.,., whether it is polymeric on non-polymeric).The table also contains information on whether AIA has identified a relevant proposed or potential derogation. Where these have been identified, the identifying paragraph and sub-paragraph of the restriction proposal (RO2) are listed. The text of each potentially applicable derogation is identified following the table. Finally, we list any supporting comments that AIA would like to draw attention to and that could provide more information on the use are included. For some uses additional information is available and included in Section 2 and a cross reference is provided to the specific section for those uses. 2 Integrated Environmental Assessment and Management 2018: Vol. 14, Number 3, pp. 316-334 3 Integrated Environmental Assessment and Management 2023: Vol. 19, Number 2, pp. 326-354 8 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 I I www.aia-aerospace.org Table 1 PFAS uses and sub-uses of the A&D sector identified by AIA Use Categories Sub-uses Semiconductor fabrication Lubricants including greases and dry lubricants Cooling fluids Valuing Sample holders Tubing Pump oils Grease Lubricant Anti-seize Thread sealant, thread lock Engine Bearings/gears/ball screws Actuators Fuel pumps Breathing/oxygen delivery systems Electronic/electrical systems O-ring seal Space/vacuum applications PFAS Type Fluoropolymer: FP Non-polymeric: PFAS PFAS & FP PFAS & FP O-rings Seals for valves, gaskets Seals Shaft or piston seals FP Seals for electronic devices Seals for bearings Nut seals Derogation PFAS: None FP: None PFAS: 5.s FP: [6.o] FP: [6.o] Supporting Comments (Submission it) Additional Information Dupont. (# 6016) United Monolithic semiconductors. (# 6342) W.L. Gore. (# 6301) Used for production of aerospace components. PFAS uses not incorporated into components. MORESCO Co. (# 4326) IKV Lubricants. (# 4001) European Sealing Association (ESA), (# 4472) Precision Polymer Engineering Ltd. (# 4501) W.L. Gore. (# 6301) ATP S.p.A. (# 4474) Repack-S. (# 4262) RADO. (# 6268) Seals are discussed in more detail in Section 2.4 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 I 9 I www.aia-aerospace.org Use Categories Sub-uses PFAS Type Fluoropolymer: FP Non-polymeric: PFAS Derogation Supporting Comments (Submission it) DuPont de Nemours, Inc.4 Additional Information Coatings Primer Topcoat Abrasion resistant coating Aluminized coating Conductive coating Erosion resistant coating High temperature resistant Temporary protective coating Conformal coating Fluorocarbon bonding preventative Adhesion promoter for polysulfide and polythioether sealants Waterproof coating Insulation material PFAS & FP PFAS: None FP: [6.o] Coatings are discussed in more detail in Section 2.3 4 EPPA, 'Submission document for public consultation ofpotential restriction of the per- andpolyfluoroalkyl substances (PFAS) related to precision polymeric parts and shapes used in high performance industrial operating environments, Report for DuPont, September 2023) Submission reference number "93f369eb-ff59-4e02-8519-8b0a1cd030d4" Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 I 10 I www.aia-aerospace.org Use Categories Sub-uses Electronics and electrical components Hydraulic fluids Heat transfer fluids Batteries (PEM in) Fuel Cells (1) also listed in High Performance Membranes Computer systems Electrical connectors Sleeves Insulators Hydraulic fluids Heat transfer fluids Fire suppressing agents Fire extinguishing agents Wires & cables Electrical components used in computer control systems Insulated cables Insulated wires Optical fibres Fluorinated gases Solvents Refrigerants Electronics cleaning Oxygen system cleaning Vapor degreasing PFAS Type Fluoropolymer: FP Non-polymeric: PFAS Derogation Supporting Comments (Submission it) Additional Information ASSCON Systemtechnik- PFAS: None FP Elektronik GmbH (# 4301) FP: [6.o] Rogers (# 6006) PFAS PFAS PFAS FP PFAS PFAS PFAS: 5.o ExxonMobil None PFAS: 5.m FP: [6.o] PFAS: 5.q & [5.dd] PFAS: 5.k & 5.1 HARC (# 4457, and follow on submission) American Pacific Corp, Halotron Division (AMPAC) Dupont Kapton (# 4530) W.L. Gore (# 6301) Amo Special Cables. (# 4479) Performance Plastics Products (# 6275) Fire suppressing agents are discussed in more detail in Section 2.1 Wires and cables are discussed in more detail in Section 2.5 Refrigerants are discussed in more detail in Section 2.6 Solvents and cleaners are discussed in more detail in Section 2.7 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 I 11 I www.aia-aerospace.org Use Categories Sub-uses Textiles Insulation blanket High performance membranes Metal plating additives (PEM in) Fuel Cells (1) also listed in Electronics and electrical components Gas and water filter membranes Hard anodic coating, FP additive Electroless nickel plating, FP additive Anti-misting agent Metal manufacturing additives Used in the production of: Seals, valves, pump bearings, hoses, tank liners, gaskets Composites and plastic parts Others Mold release Parting film Composites Molded plastic parts Adhesives Tapes Damper/cushion for clamps Low friction wear strips Military decoy flares Abrasive cloths PFAS Type Fluoropolymer: FP Non-polymeric: PFAS FP FP PFAS FP PFAS PFAS & FP FP Derogation PEAS: None FP: [6.o] FP: [6.o] PFAS: [5.v] FP: [6.o] None PFAS: None FP: [6.o]/None FP: [6.o] Supporting Comments (Submission it) Additional Information SAXONIA Galvanik GmbH. (# 6097) Used for production of aerospace components. Watson-Marlow Fluid Technology Solutions. (# 3977) LEUSCH GmbH Industriearmaturen. (# 6338) Used for production of aerospace components. Kitamura Ltd. (# 4188) Toray Advanced Film Co. (# 4290) Composites are discussed in more detail in Section 2.8 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 I 12 www.aia-aerospace.org Text of derogations relevant to uses of PFAS and FP identified by AIA: 5.k industrial precision cleaning fluids until 13.5 years after EiF 5.1 cleaning fluids for use in oxygen-enriched environments until 13.5 years after EiF 5.m clean fire suppressing agents where current alternatives damage the assets to be protected or pose a risk to human health until 13.5 years after EiF 5.o additives to hydraulic fluids for anti-erosion/anti-corrosion in hydraulic systems (incl. control valves) in aircraft and aerospace industry until 13.5 years after EiF 5.q refrigerants in transport refrigeration other than in marine applications until 6.5 years after EiF 5.s lubricants where the use takes place under harsh conditions or the use is needed for safe functioning and safety of equipment until 13.5 years after [IF; 5.v [hard chrome plating until 6.5 years after EiF]; 5.dd [use as refrigerants and for mobile air conditioning in vehicles in military applications until 13.5 years after EiF]" 6.o [applications affecting the proper functioning related to the safety of transport vehicles, and affecting the safety of operators, passengers or goods until 13.5 years after EiF] Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 I 13 I www.aia-aerospace.org 1.7 Alternatives and Substitution Timelines Noting that the identification of aerospace and defense uses is still ongoing, a full assessment of the availability and suitability of alternatives is only at the beginning stages. A detailed analysis must be completed for each use and sub-use. The continued use of various PFAS chemicals (including FPs) in aerospace and defense products is desirable as these uses are a small fraction of the global utilization of PFAS chemicals yet provide significant societal benefit. Today, there are no known substitutes for PFAS chemical materials with their unique properties partly because the alternatives will also be persistent in nature and will also result in poorer performance overall. Finally, the diminution of functional characteristics is unwarranted and will lead to other unintended consequences especially in aerospace and defense applications where their use is much needed. (A&D products operate in extreme environments, over extended time frames, while having to fulfill significant safely, reliability and technical requirements. Global airworthiness regulations ensure A&D products' safety and reliability. These regulations require a systematic and rigorous framework to be in place to qualify all materials and processes to meet stringent safety requirements that are subject to independent certification and approval through EASA (European Union Aviation Safety Agency), Federal Aviation Administration (FAA) and other national agencies. Air, ground and sea-based defense systems, and also space systems, are subject to similar rigorous qualification requirements. Meeting approvals requires validation and certification of all products used. Because PFAS-containing products have proven reliable in safety critical A&D applications, the industry has not needed to develop or seek alternative products and materials. The state of available alternatives today is similar to that for hexavalent chrome uses in the late 1980s, when the aerospace and defense sector first started alternative development efforts -- alternatives are still not available for all hexavalent chromium uses over 30 years later. While some uses may be fully substitutable in a shorter time, it is not possible to predict with certainty which ones. Given the widespread uses of polymeric and non-polymeric PFAS in the A&D sector, and the extensive validation, certification and industrialisation work OEMs undertake for all affected specifications, components and products, it will take a lengthy (and currently unknown) period of time to identify and implement substitutes. To help convey the challenges involved in alternatives development and deployment for A&D uses, we call your attention to a paper produced by the Global Chromates Consortium for Aerospace's (GCCA), titled Aerospace & Defence Qualification Process Impacts on Ability to Substitute Cr(VI) Substances which is attached to this submission. Although the GCCA paper was written to support hexavalent chromium Authorisation applications, the qualification and certification processes described are also applicable to substitution of other substances, including PFAS within the A&D industry. The following illustration included in that paper supports the length and uncertainties of the substitution timeline discussed in the previous section. 14 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 l www.aia-aerospace.org Testing failure paths Development of Potential Candidate Innovative R&D to develop new corrosion protective systems formulation Lab testing Iterative fre)fonnulation & testing TRLO - TRL3 Qualification of Test Candidate Extensive generic lab testing Iterative testing if failures Validation of Test Candidate * Test plan creation and approval Component spedfic testing System /Engine/ flight testing Manufacturing trials Review & approval of test results TRL4 --TRL6 Certification of Alternative Test plan creation and approval Component/ system/ engine / flight testing Review & approval of test results Drawing release Manual creation / revision Industrialization of Alternative Identification of Manufacturing source Purchase & installation of capital equipment Process verification QC approval Possible Regulatory approval TRL7- TRL 9 Formulators Manufacturing Supply Chain OEM; multiple departments Regulators * Failure at any stage can require reverting to the beginning of the process with new potential candidates Airlines and Maintenance, Repair, and Overhaul companies Figure 1. Illustration of the development, qualification, validation, certification and industrialisation process required in the aerospace industry -- adapted from the GCCA paper on Aerospace & Defence Qualification Process Impacts on Ability to Substitute Cr(VI) Substances3. The GCCA paper provides the following important statement: "The complex relationship between each component and its performance requirements within its own unique design parameters requires certification of each substitution individually (see Figure 2). Qualification in one particular application does not guarantee that use in another application is qualified. Every application must be individually assessed to determine that requirements are met. This process must be independently replicated across all A&D products by each A&D company. A&D products (e.g. a specific aircraft model) may be in service for 30-50 years (even longer in defense uses), requiring maintenance, repair and spare parts over their entire service lives. Any changes to these parts or processes must be fully validated and certified to ensure safety and performance are not compromised." ConiqmmtsA4K Systems0 9 R 99 %.6. "6"Psbwa Subsystem N 90 Subsystem 0 [ Subsystem P Subsystem N Subsystem 0 System R ( Subsystem L ) Subsystem L Subsystem M Subsystem IA System Component testing x=m0===mkm=mk 15 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 I I www.aia-aerospace.org Figure 2. Systems assessment and validation overview, taken from the GCCA paper on Aerospace & Defence Qualification Process Impacts on Ability to Substitute Cr(VI) Substances'. The R&D process for finding suitable PFAS-free alternatives to the articles and formulations described in this comment will be robust but complicated. Our industry is still in the early stages of initiating R&D processes to find PFAS-free alternatives. Safety and quality considerations will be paramount given the nature of our industry. The R&D processes will require collaboration between major material suppliers, designers, and parts manufacturers. A key complicating factor is that once suitable PFAS-free alternatives have been identified within the industry, certain PFAS substitution efforts will almost certainly require the approval of the EASA and the U.S. FAA. Such approval processes can take many months if not years. If viable PFAS alternatives can be identified, best case replacement efforts would require at least 0.5 year of research and require at least 186,000 ($200,000 USD) per material, with a likelihood of successful completion of 75%. Once developed, these formulations would need to go through validation, testing and certifications processes If no viable PFAS alternatives exist, requiring the development of new materials, a more extensive research effort will be required. This effort would include the following, with the following costs attributable for one member company of our organization: i) New material discovery, manufacture, and scale up (3.7-5.6MM; $4-6MM USD) ii) Application development, including material handling, formulation, manufacturing set up, part design, and manufacture (75MM; $80MM USD) iii) Extensive testing to ensure the materials, formulations and articles have the critical quality requirements required for the application (45-60MM; $48-64 MM USD) iv) Certification and component testing (1-3MM; $2-3MM USD) v) Change in Design (CID) processing, including engineering and regulatory reviews (2MM; $3MM USD) For one member company of our organization, the overall research effort is expected to last at least 10 years and cost at least 136-187 MM ($145-200 MM USD). To reiterate, given the strict qualification and certification requirements in place for A&D products, substitution, of PFAS chemicals would mean that many hundreds of thousands of parts designed, integrated, approved and certified for aviation and other A&D systems would need to go through a requalification process if and when suitable alternatives have been identified. The scale of the substitution effort that would be required based on the current restriction proposal has no precedent as thousands of formulations, parts, components, systems etc. across all A&D products would be in scope. Technical and monetary resources currently engaged in substituting other heavily regulated materials of concern such as hexavalent chromium will get diverted, thus hindering their progress. The aviation industry has committed to achieving net-zero flying carbon emissions by the year 2050 and increased use of Sustainable Aviation Fuel (SAF) is one of the key enablers being actively pursued. Aerospace OEMS are evaluating and qualifying new SAF pathways for unrestricted use in commercial 16 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 I I www.aia-aerospace.org and military engines. Both blended and 100% SAF are currently being tested for their compatibility with the materials currently in use for aircraft engine oil and fuel systems. These include the seals, O-rings, gaskets, and hoses discussed in section 2.4. If new material is introduced to replace polymeric PFAS, all the testing will need to be repeated in order to ensure compliance with airworthiness regulations. This will be a major setback for the net-zero by 2050 goal. 1.8 Socio economic analysis (SEA) issues In this section, AIA considers the socioeconomic impacts of a restriction on PFAS as currently proposed where derogations cover some, but not all, aerospace and defense uses. It might be worthwhile to consider the nature of the A&D industry within the REACH member states. The European Commission has summarized the economic impact of aerospace within Europe as follows: Air transport makes a key contribution to the European economy, with more than 100 scheduled airlines, a network of over 400 airports, and 60 air navigation service providers. The aviation sector directly employs between 1.4-2 million people and directly or indirectly supports 4.7-5.5 million jobs. Aviation directly contributes more than 110 billion to the European gross domestic product (GDP). Some 900 million passengers departed or arrived at EU airports in 2014. Linking people and regions, air transport plays a vital role in the integration and the competitiveness of Europe, as well as its interaction with the world.5 The socioeconomic impacts of the PFAS restriction will clearly depend on its scope as the discussion below explains. RO1 option -- a full PFAS ban: The Annex E report concludes the following with regard to the cost impacts of a total PFAS ban on the Transport sector without appropriate derogations: In the event of a full ban, there would be significant disruption to the industry leading to very high producer surplus losses including business closures, which would also lead to substantial employment losses. In the event that it is possible to produce vehicles, there is also a strong likelihood of consumer surplus losses through the sale of vehicles with limited capabilities and reduced reliability.' While this language is direct and alarming, we do not believe it sufficiently captures the scale of costs that the proposed restriction would impose on the REACH member states. The proposed restriction as written would prevent the use or placing on the market of PFAS above certain concentrations in articles. While the restriction's applicability to new articles may be more straightforward, the biggest impact of the restriction would be on aircraft engines flying in and out of the REACH member states. These aircraft--some with 30+ year lifecycles (where PFAS contributes greatly to this longevity due to the strength of the C-F bond) --will continue to require new or refurbished parts that contain PFAS. Removing all PFAS-containing components from these aircraft will require a massive multi-year 5 See European Commission, Internal market, available at https://transport.ec.europa.eu/transport- modes/air/internal-market en 'Table E.121; page 372. 17 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 l www.aia-aerospace.org retrofitting effort. A total PFAS ban within 18 months without appropriate derogations would prevent existing aircraft from getting necessary maintenance and service within the REACH member states. It is not exaggeration to say that this would result in nothing short of a significant disruption, if not a near complete shutdown, of air travel to, from, and among the REACH member states. Simply put, if no derogations are provided for A&D or other safety critical aspects of the Transport sector, air travel within the REACH member states would not be able to occur compliantly for many years, putting the entire A&D industry within Europe at grave risk. It is not unreasonable to compare such a scenario to the economic impacts of the COVID-19 pandemic impact on the aerospace industry, where global travel slowed to a halt and flights were grounded worldwide. According to a 2023 study by the International Civil Aviation Organization, the pandemic caused total passenger revenues in Europe to decrease 92 billion ($100 billion) in 2020, 81 billion ($88 billion) in 2021, and 37 billion ($40 billion) in 2022, vs. 2019 figures.' These figures do not account for the massive job losses and other downstream costs to the EU economy. In short, the restriction as proposed without amendment (including an appropriate derogation accounting for transport safety) would create catastrophic economic impacts on the REACH member states. RO2 -- a PFAS ban but with the proposed derogations, but without the proposed derogation under reconsideration in 6.o: We believe that the discussion above applies nearly equally to the RO2 option without significant revision and without inclusion of a derogation accounting for safety in Transport. The most severe impacts would occur earliest at the time the end of the 18-month transition period when no parts or products containing PFAS or fluoropolymers without a derogation would be allowed to be introduced to the EU market. In the case of A&D products, where every part and component are essential, this means that any one component containing PFAS that cannot be replaced would stop delivery of the entire aircraft or product. In reality, of course, this would be numerous parts and components. However, when considering individual parts and components, such as spares, parts not containing PFAS would be unaffected. But parts containing PFAS and covered by a derogation could still be imported, and those not covered could not be. This situation would shift over time if some PFAS uses are able to be substituted, but at 6.5 years the first tranche of derogations expires and increases the number of parts that cannot be imported. The situation repeats again at 13.5 years with the last tranche of derogations expiring. Of course, the future availability of qualified, validated and certified alternatives for any specific use is not known today, but we can predict with high confidence that there will be some (and probably many) uses where there will not be available alternatives and there will be many PFAS containing parts (especially those with fluoropolymers which we expect to be especially difficult if not impossible to substitute) remaining that could not be imported. Thus, at 13.5 years no PFAS containing spare parts and no products/aircraft could be imported into a REACH member state. Through this entire timeline AIA member companies would be able to continue providing products to customers outside of the EU, but inside the EU newly produced aircraft would be unavailable except for foreign owned aircraft landing at EU airports. It would also place sharp limits on EU military 7 See ICAO, Effects of Novel Coronavirus (COVID-19) on Civil Aviation: Economic Impact Analysis (April 27, 2023), slide 65, available at https://www.icao.int/sustainability/Documents/Covid- 19/ICAO coronavirus Econ Impact.pdf. 18 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 l www.aia-aerospace.org interoperability with international treaty partners that rely on fluoropolymers and other PFAS in their defense equipment. Let's also consider the uses of PFAS. AIA member companies do have some of their own operations based in the EU as well as significant networks of suppliers that produce parts and components (and sometimes full finished products) for products and aircraft that are produced in the US. At the end of the 18-month transition period all uses of PFAS in the EU without applicable derogations would have to cease. However, these same processes could still be performed in the US or other non-EU countries, and AIA member companies would evaluate moving these production processes out of the EU. Shifting large quantities of work would not be done cheaply, so this would be a significant economic impact. Similar to the previous case with importation of PFAS containing parts, there would be two more tranches of activity at 6.5 and 13.5 years when derogations expire for uses without available alternatives. The situation is similar for maintenance, repair and overhaul (MRO) of aircraft. Non-derogated maintenance activities currently done in the EU would have to shift outside of the EU to continue using PFAS where there are not available alternatives. More maintenance activity would have to shift as derogations expire at 6.5 and 13.5 years. It is unclear under this restriction proposal if a repair that incorporates PFAS into the product (e.g. replacement of a PTFE rub strip) without a derogation would prevent the return of the repaired product/aircraft to service in the EU. In this regard AIA supports the repair as produced principle where products should be allowed to be repaired as originally designed and produced (Orgalim)8. 1.9 Sectors This comment provides information relevant to the aerospace and defense sector. In the restriction report, A&D is combined with the transport sector. While there are many similarities between A&D and the broader transport sector, products in the A&D sector must meet exacting performance requirements and operate in more extreme environments. Change processes for A&D products are also highly regulated and deliberate to ensure continuity for product performance and safety. For these reasons A&D will likely require different, most likely more and longer, derogations than the rest of the transport sector. Thus, we suggest that aerospace and defense should be treated as a distinct sector. A&D also relies on products from other sectors to be integrated into A&D products. AIA is aware that many of these sectors have already made comments or are planning to make comments to this restriction proposal. We are also aware of individual companies in said sector making supplemental comments. In many cases these comments identify the reliance of A&D (and other sectors) on their products. AIA wishes to emphasize that where a sector does not identify reliance of A&D on their products does not necessarily mean there is not a reliance on their product. It is also important to recall that timelines for A&D to adopt potential alternatives can be very long and potentially exceed estimates of the sectors upon which we rely. 8 https://orgalim.eu/sitesidefault/files/attachment/Orgalim%20PFAS%20position%20paper_310823.pdf 19 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 l www.aia-aerospace.org 1.10 Emissions and Recycling in the End of Life Phase The Aircraft Fleet Recycling Association (AFRA) establishes standards and best practices which it uses as a basis for its accreditation program for aircraft disassembly and aircraft materials recycling.' Similarly, Tarmac Aerosave is an independent European company actively engaged in decommissioning and recycling.10 More information about both programs is described in the International Civil Aviation Organization (ICAO) 2019 Environmental Report.' Aircrafts are considered valuable assets even at the end-of-life due to the specialized, high performance material contained in them. Comments submitted to this consultation by ASD, provide more information on how commercial aircrafts are stored, recycled and disposed at the end of life. The end-of-life management of military equipment is even more closely managed as is a highly sensitive subject for national security reasons. 1.11 Proposed derogations With regard to derogations, AIA acknowledges that derogations are proposed for some PFAS uses that are relevant to the aerospace and defense sector. However, not all aerospace uses or sub-uses of PFAS have derogations in the restriction proposal. The list of uses and sub-uses identified by AIA in section 1.5 identifies which uses appear to be "covered" by a derogation and would thus have an additional 5 or 12 years to fully implement alternatives. Many uses, especially of non-polymeric PFAS, do not appear to correspond to any applicable proposed derogation at all. These uses would then have to cease at the end of the transitional period. It appears that most polymeric PFAS uses would fall under a potential 12 year derogation [6.0] under consideration for the broader transportation sector. It is not guaranteed that any of these potential derogations would provide sufficient time to make substitutions in an orderly and carefully controlled manner that is necessary for all our products. AIA also wishes to reemphasize the importance of highly deliberate change processes that ensure continued operational safety of aerospace and defense products. As described in Section 1.4 substitution timelines can take many years to ensure that all performance requirements are satisfied. Failure to do so can lead to catastrophic results. In the case of substituting PFAS we will need to perform this process many times over for each use that needs to be substituted. We do not yet even know the number of changes (we are still in the process of identifying all uses, and a preliminary listing of uses is provided in Section 1.6 that addresses the specific information request on sectors and (sub-) uses) that would need to be done as a result of this proposed restriction, nor do we have an idea how long each individual substitution would take. But we can say with certainty that 18 months would not be long enough to bring all required aerospace and defense changes through all stages of the process. Where there are longer derogations proposed it is improbable that some substitutions could be completed. 9 https://afraassociation.org/ 10 https://www.tarmacaerosave.aero/ 11 https://www.icao.int/environmental- protection/Documents/EnvironmentalReports/2019/ENVReport2019 pg279-284.pdf 20 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 l www.aia-aerospace.org The question then becomes how long would the aerospace and defense sector require to complete substitutions for each use or all uses. This, unfortunately, is unknown at this point. We simply lack all of the information needed to respond here. Among the unknowns: Uses and sub-uses of PFAS in the supply chain Identity of non-PFAS candidate alternatives to test for each use and sub-use Resources required to adequately evaluate all substitutions; Whether any particular substitution will be an interchangeable global change or need to be done on a part by part basis Since the neither the generic 18-month transition period nor the fixed duration derogations are sufficient for aerospace and defense uses and sub-uses, we propose that a derogation be included for all uses and sub-uses of PFAS chemicals in the aerospace and defense sector. The derogation should include technology readiness evaluations to determine whether alternatives are available for any uses and sub-uses and what appropriate adjustments should be made to the duration of the derogation. 1.12 Potential Derogations Marked for Reconsideration While we strongly urge the inclusion of a derogation specific to the A&D sector as described above in section 1.9, we also strongly support the inclusion of the following potential derogation marked for reconsideration: 6.o, "applications affecting the proper functioning related to the safety of transport vehicles, and affecting the safety of operators, passengers or goods until 13.5 years after EiF." We respectfully provide the following information in support of this potential derogation. As discussed above, the annual tonnage and emissions of PFAS associated with this sub-use is not possible to quantify at this time. In summary though, we believe that PFAS plays a critical role in ensuring the safety of various components in aircraft and defense. As explained elsewhere in these comments, the types of PFAS that we have identified serve critical safety functions of heat and fire resistance, fluids chemical resistance, vibration resistance, corrosion resistance, and wear resistance. Many of their uses are described in Table 1 above. Their use qualifies as "applications affecting the proper functioning related to the safety of vehicles, and affecting the safety of operators, passengers or goods." We estimate that this restriction would directly affect hundreds of different companies in the aerospace industry, including aircraft engine manufacturers and their supply chains, with resulting indirect impacts on airframers, airliners, and their customers. The total number of companies within our industry estimated to be affected by the restriction is estimated to be in the thousands. We wish to provide comments on the alternatives and cost impact of the proposed restriction on the A&D portion of the Transport sector and particularly on the PFAS sub-use relating to applications 21 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 l www.aia-aerospace.org affecting the proper functioning related to the safety of vehicles.12 The Annex E report concludes the following with regard to the availability of alternatives to PFAS within the Transport sector: The transport sector has an extremely high dependence on PFASs, including use in complex products (e.g. seals, 0-rings and gaskets in engines). The properties of PFASs can provide input to the design of such products, with the result that drop-in substitutes will not always be available. Even where they are, testing and certification procedures would need to be followed. It is therefore concluded that a full ban is not feasible for the transport sector and that substitution potential is low.13 We agree with this statement but wish to reiterate that for the formulations and articles discussed above, there are currently no available PFAS-free alternatives for such products on the EU market (or elsewhere globally) that we have yet been able to identify. The concern is particularly acute in the context of aerospace servicing and manufacturing given the rigorous safety and qualification process that are required of any changes to engine design and specification. Please see the discussion in Section 1.8 concerning the socioeconomic impacts of a restriction without inclusion of this potential derogation. As described in Section 1.5 alternatives for fluoropolymers (and PFAS) are not available because R&D into potential alternatives has only just begun. This will be a complex and expensive process. As alternatives are not yet available we do not have information to provide regarding cases where substitution is technically and economically feasible or where substitution is not technically or economically feasible. 12 Annex XV restriction report, pp 101-102; Annex E, pp 346-387. 13 Table E.121, page 372. 22 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 l www.aia-aerospace.org 2 Aerospace PFAS Use Examples The following section provides more commentary on several of the uses and sub-uses presented in Table 1. Where possible, we have added information on describing the use(s) in A&D applications, key functionalities, the current state of knowledge on alternatives and adequacy of any potential derogations. It is noted that not all uses in Table 1 are covered here and those not included should not be considered as less important to the A&D sector. 2.1 Fire Suppressing Agents In general, there are many classes of fire suppressing agents including water, inert gases, carbon dioxide, and vaporizing liquids (referred to as Clean Agents in NFPA nomenclature. Clean agents extinguish fires rapidly, leave no residue, are efficient (i.e., they have excellent space/weight characteristics) and are safe to use where humans are present. For this reason, they are required for protection of high-value assets, e.g., computer rooms, nuclear power plants, aviation and military applications. There are two main approaches to extinguish fire: either fill the entire space with the required amount of fire extinguishing agent, a process known as "total-flooding", or directing the fire extinguishing agent at the source of the fire (if it is known), a process called "local application or streaming". A class of halogenated hydrocarbons or halons were identified as particularly effective in a joint study by Purdue University and the US Army14. Halons were fully commercialized in the 1970's and formed the mainstay of clean agent fire protection of over 20 years until they were implicated in ozone depletion. Under the Montreal Protocol, production of halons ceased in 1993 in developed countries and 2010 in developing countries. For total flooding applications bromotrifluoromethane (CF3Br, Halon 1301) was preferred, whereas for local application bromochlorodifluoromethane (CF2BrCl, Halon 1211) was preferred. However, the need for fast, effective, clean agents had not gone away and the fire protection industry has been developing alternatives to halon for the last 30 years. Alternatives including HCFCs, HFCs, inert gases, and a perfluoroketone were developed as clean agents for total-flooding applications and HCFCs, HFCs and 2-bromo-3,3,3-trifluoropropene were developed as streaming agents. More recently, HCFCs are subject to a phase-out under the Montreal Protocol, and since the issue of global warming, HFCs are being phased down, e.g., under the EU F-gas regulations. This leaves aerospace and military fire protection in a difficult situation. The proposed PFAS regulations remove all candidate agents, apart from halons, CF31 and HFC-23. The specific implications for aerospace and military fire protection applications are discussed in the following section. 14 Purdue Research Foundation and Department of Chemistry. "Final Report On Fire Extinguishing Agents for the Period September 11, 1947 to June 30, 1950." Purdue University, West Lafayette, IN, July 1950. 23 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 I I www.aia-aerospace.org 2.1.1 Fire extinguishers used on-board aircraft 2.1.1.1 Description of Use In commercial aircraft fire suppression agents utilizing Bromochlorodifluoromethane (Halon 1211) or Bromotrifluoromethane (Halon 1301) have been used in 4 main systems described below. Application Handheld Cargo Lavatory Propulsion Historic Use Halon 1211 Halon 1301 Halon 1301 Halon 1301 Replacement The most common non-halon handheld fire extinguisher agent that is in use on commercial airplanes is 2-BTP (CF3CBr=CH2). Replacements have been ongoing since 2019. 2-BTP is PFAS according to the definition in this restriction proposal. The only non-PFAS alternative would be to revert to using Halon 1211. However, this would be in contradiction of the EC Regulation 1005/2009 as amended by (EU) 744/2010. A blend of CO2 and 2-BTP is the leading candidate for cargo applications. 2-BTP is a PFAS according to the definition in this restriction proposal. Non-PFAS alternatives in the form of water mist plus inert gases or inert gases alone have been evaluated but these approaches would entail significant space and weight penalties as well as a more complex certification approach. HFC-227ea (CF3CHFCF3) and HFC-236fa (CF3CH2CF3) have both been used as replacements for Halon 1301 in lavatory waste compartment fire protection'. (PFAS) There are no other clean agents that are not classed as PFAS. CF31 is precluded owing to its toxicity profile. The only non-PFAS alternative would be to revert to using Halon 1301. However, this would be in contradiction of the EC Regulation 1005/2009 as amended by (EU) 744/2010. CF31 is the top candidate for propulsion applications. (Not PFAS) The ozone depletion and global warming potential of the traditional CF3Br (Halon 1301) suppression agent necessitated the development of suppression agents. The alternative agents have not as yet been successful at suppression in all circumstances, but the one thing they all have in common are carbonfluorine bonds. This is of particular importance for fire suppression because even after the donation of a more loosely-bound halogen like iodine or bromine to the catalytic flame suppression reaction, the base molecule must remain stable in the hot environment. The base molecule must also have little or no bonded species that can be oxidized to CO2 and water as this would promote rather than suppress flame. The combination of carbon-fluorine bonds (with their inherent stability) and carbon bonded to another catalytic halogen (e.g., bromine), provides suppression of flames which are the primary driver of fire spreading to new fuel sources. For gas phase fire suppression chemicals to work they must either absorb heat or release an atomic species that will catalytically quell the flame front, or both. The binary agents are combinations of these two methods using CO2 to absorb heat and a molecule that will release bromine atoms (the catalytic is https://www.icao.int/Meetings/a41/Documents/WP/wp_096_en.pdf 24 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 I I www.aia-aerospace.org agent). The molecule that releases bromine at the flame front must be stable enough to survive the trip to the flame front at high temperature. Current methods include the use of chemicals such as 2-BTP (2bromo-3,3,3-trifluoroprop-1-ene), here the inherent strength of the carbon-fluorine bond is utilized to gain enough molecular stability to release the bromine at the flame front. There are still two hydrogencarbon bonds that can be oxidized in the fire which is why this chemical cannot be used on its own (i.e., without CO2). Without carbon dioxide the 2-BTP is oxidized in the gas phase by gas phase fuel fires; which is not acceptable for mixed fuel fires such as aircraft cargo fires. 2.1.1.2 Key functionalities Required functionality generally includes the following. Ability to extinguish fires, material compatibility (e.g. with materials found on aircraft), toxicity, low ozone depletion, low global warming potential weight 2.1.1.3 Availability, technical and economic feasibility, hazards and risks of alternatives The only current alternative for 2-BTP would involve reverting to Halon 1211 for handheld fire extinguishers. As previously stated, Halon is not an acceptable nor available alternative. Subject to Montreal Protocol, o Ozone-depleting substance o High global warming potential o Global production has ceased o Subject to phaseout in 2025 under EC Regulation 1005/2009 as amended by (EU) 744/2010. Limited available global supply 2.1.1.4 Status ofR&D where alternatives not available Fire suppression is also an example of there not being a universal answer when seeking a chemical solution to an environmental problem. In the last four years several experiments in a full-scale fire suppression test facility have shown that a different set of chemical constraints are important to the function of fire suppression materials. Two "not-in-kind" technologies have been extensively evaluated. Inert gas, either used alone or combined with water mist has been shown to be capable of extinguishing the types of fires encountered in cargo compartments. However, the space and weight requirements for a high-pressure inert gas system are prohibitive. An AIA member company has proposed inert gas on numerous responses to Requests for Information (RFIs) or Requests for Proposal (RFPs), and on each 25 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 I I www.aia-aerospace.org occasion the aircraft OEM was not able to integrate the much larger and heavier system into the airplane. Inert gas systems have also not been tested to the latest FAA/EASA Minimum Performance Standard test. CF3Br vs. CF31 has been extensively investigated. Iodine is next down in the halogen column from bromine. The C-1 bond is less robust and thus the CF31 molecule has a much shorter half-life in the atmosphere (on the order of days). However, one step down the periodic table was too large a jump in bond strength. CF31 failed to suppress a smoldering cargo fire and decomposed via several free radical mechanism to CO2, 12 and HF (hydrofluoric acid) which is not the desired outcome. For liquid fuel fires CF31 is quite effective when applied directly on the fire, and it can also suppress fires caused by exploding aerosol cans in the cargo hold of an aircraft. But it cannot control a smoldering fire due to the low bond energy of the C-1 bond. Binary fire suppression agents are now being tested. These combine CO2 and other agents to achieve desirable performance in the case of a fire, but they weigh more and require more complex suppression system designs that are also heavier than those for a single component suppression agent. However, the blend of 2-BTP/CO2, as noted above, is the leading agent to replace Halon 1301in cargo compartments. While CF31 is a non-PFAS alternative being explored for propulsion applications it has been ruled out for cargo applications. It was evaluated thoroughly in 2019, and failed the smoldering fire test. It has not been considered as a candidate an alternative for handheld or lavatory applications because of its toxicity profile. Handheld and lavatory fire protection applications are in areas where people are present, and the use of CF31 would exceed maximum safe concentrations. 2.1.1.5 Information on substitution where alternatives are available The only area of fire protection where a non-PFAS is being considered is that for propulsion / APU, where CF31 is one of the agents being evaluated. CF31 has passed the minimum Performance Standard 2.1.1.6 Socio-economic impacts The proposed restriction includes a derogation for "clean fire suppressing agents where current alternatives damage the assets to be protected or pose a risk to human health until 13.5 years after EiF". This will have the effect of delaying the eventual outcome of a non-use scenario. The continued use of Halon 1301 would create a crisis of its own, as global supplies are projected to run out as soon as the mid-2030s. This would leave airlines with two very untenable choices -- continue to use Halon 1301, which would require a change to the Montreal Protocol to allow new production as recycled Halon 1301 can no longer address demand, or switch to the 2-BTP/CO2 blend, which would be restricted and require removal in approximately 2038. The two are not interchangeable without a significant airplane modification. The uncertainty created by the proposed restriction will prevent adoption of the halon alternative, which will increase the chance of a requirement to produce new Halon 1301 or ground the European airline fleet. 2.1.2 Conclusion and adequacy of proposed/potential derogations Substitution of Halon fire suppressants has been time consuming and difficult to complete. Original development efforts began in 1990 for all 4 main applications. Lavatory applications were successfully substituted starting in 2006. Substitution of handheld fire extinguishers began in 2019. As noted previously, efforts for cargo and propulsion are still ongoing meaning the overall substitution timeline to 26 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 I I www.aia-aerospace.org move away from Halon will be greater than 25 years, assuming the current candidates are successful. Considering the challenges and time duration to get to this point, it is not unreasonable to conclude that substitution with non-PFAS, non-Halon, alternatives meeting all requirements would take much longer than 13.5 years, if an alternative can be identified at all. Recalling the bond energies carbon-fluorine compared with other carbon-halogens, new non-fluorinated chemicals with low GWP are not currently foreseen and 13.5 years is inadequate. We cannot predict if or when a new candidate will become available to test, so it would not be prudent to suggest a different duration. We also acknowledge that requesting a permanent derogation for this use may not be palatable for certain parties. Rather, we would suggest an open-ended review period with periodic technology review checkpoints. 2.1.3 Fire extinguishers used in military fighting vehicles Many of the arguments presented in Section 2.1.1 above are equally applicable to military vehicle fire protection, so will be summarized briefly here. The requirements for military applications are in some ways more demanding and HFCs remain the only viable extinguishing agent type, other than halons, for military vehicle protection. In the military environment large fast-growing fires can be encountered. In the case of military vehicles, the extinguishing system in crew compartments is required to extinguish an explosion in an occupied space very rapidly (<150 milliseconds). If the extinguishment takes any longer than this there is a risk of burns to the vehicle occupants. The extinguishing agent must be safe to use at its design concentration, must generate acceptable levels of decomposition products, and also provide protection against reignition. In addition, the extinguishing agent is required to provide protection across a wide temperature range. Currently only HFC agents (HFC-227ea and HFC-236fa) can meet these exacting criteria. Both of these are classified as PFAS. Considering the alternatives to HFCs: Water freezes, so it does not meet the temperature specifications and is therefore not an option. Whilst the addition of antifreezes can prevent freezing, the nature of the fire means that a gaseous agent is required to prevent the fire re-igniting. Water has been extensively tested and it has been shown that fire can reignite, which means that water-based fire extinguishing agents are not appropriate for military vehicle fire threats. Inert gases require too much space and weight and are therefore also not appropriate for military vehicle fire threats. The only other current alternatives are Halons 1301and 1211. However, these have high ozone depletion potentials as well as high global warming potentials. Reverting to halons would be considered as a "backward step" as well as being in contradiction to EC Regulation 1005/2009 as amended by (EU) 744/2010. 27 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 l www.aia-aerospace.org 2.2 Hydraulic fluid Commercial airplane hydraulic power systems are used for actuation of primary and secondary flight control surfaces, extension and retraction, steering, and brakes for landing gear systems, cargo doors, engine thrust reversers, and other services requiring precise control of large operating loads. Military airplane hydraulic systems share commonality with commercial type services where applicable, but include many others such as: weapon bay doors, drives for guns and the delivery of missiles and other ordnance material, aerial refueling equipment, auxiliary power unit (APU) start systems, catapult and arresting hooks, radar antenna, and emergency generator drives. Missile, rocket booster, and space vehicle hydraulic systems are used primarily for controlling vehicle flight path by vectoring engine thrust and controlling aerodynamic surfaces. Helicopter hydraulic systems are used for controlling the rotor swashplates in both the cyclic and collective pitch modes, for stability augmentation servos, tail rotor blade pitch control, hoist winches and cargo hooks, landing gear retraction, brakes, steering, and APU and engine starting. 2.2.1 Key Functionalities The control of streaming potential (movement of ions in hydraulic fluids that cause electrochemical corrosion) is done by the use of polyfluorinated surfactants. These surfactants also increase the lubricity (lowering friction) of the hydraulic fluid that limit wear on safety critical components of the hydraulic systems in aircraft, space vehicles and submarines as well as all other hydraulic systems that use nonflammable hydraulic fluids. One of the important factors in designing any hydraulic system for aerospace applications is its weight contribution to aircraft. Lower weight of the hydraulic system provides higher fuel efficiency and less global warming gasses are released during flight of aircraft and space vehicles. To lower the overall mass of the hydraulic system, smaller, lighter tubes and components are used, but this requires the hydraulic fluid to be pumped at higher pressures. In so doing the overall volume of hydraulic fluid in the system is also reduced. In order to smoothly control the aircraft or space vehicle, the pressure must be reduced at the electrohydraulic servo valve (EHSV). While reducing pressure, streaming potential becomes a larger and larger problem as the pressure of the hydraulic system increases. In order to solve problems associated with the operation of the EHSVs at higher and higher pressures, more polyfluorinated surfactant has been needed. The unique characteristics of the carbon-fluoride bonds in these surfactants, accounts for their ability to both provide the lubricity needed under the extreme conditions in the hydraulic pump, and in their ability to quell streaming potential. The combined low acid production along with these other attributes make this surfactant irreplaceable in high pressure hydraulic fluids today. Please also refer to the comment submitted by ExxonMobil which provides a thorough description of the erosion mechanism. Required functionality generally includes the following. Must be able to operate at high pressure (e.g. 3,000 -5,000 psi) Minimize streaming potential that leads to electrochemical corrosion Low corrosion / erosion rate 28 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 l www.aia-aerospace.org 2.2.2 Alternatives and Conclusion One supplier of aerospace hydraulic fluids reports that non-fluorinated erosion inhibitors have been tested in past decades with less severe system designs, but that no potential replacement chemistry has been identified with adequate stability to survive in hydraulic fluid in aircraft service. Considering that decades of testing have not yet yielded any promising non-PFAS results, we are not confident that a promising candidate will be identified soon. However, any future promising candidate that is identified must successfully progress through the entire change process described in Section 1.7. Because of the importance of hydraulic fluid systems for flight control, functional testing necessary for validation and certification is expected to be extensive and affect the overall timeline for substitution significantly. The proposed restriction includes a derogation for "additives to hydraulic fluids for anti-erosion/anticorrosion in hydraulic systems (incl. control valves) in aircraft and aerospace industry until 13.5 years after EIF". Considering the discussion above, we lack certainty if this derogation is long enough, and a derogation with periodic evaluation of the availability of current technology is requested. 29 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 l www.aia-aerospace.org 2.3 Coatings -- Organic finishes Organic finishes are an important category of uses for the aerospace and defense sectors. As in other sectors, coatings impart important functionality to the parts to which they are applied. Due to their strong influence on safety and reliability of the product, organic finishes are closely controlled by Government/military standards, Federal regulations, and OEM material and process specifications. Organic finishes are used on materials for environmental protection and for aesthetic appearance. They include primers, topcoats, and certain specialty coatings. The selection of finishes is usually predetermined or limited by contractual or product model finish specifications. Selection of finishes begins with the identification of finish requirements as determined by the following: Function of the coating Contractual or product requirements Required operating environments Manufacturing and handling environments Fluorinated compounds may be used in coatings as wetting, leveling, and dispersing agents, and have been used to improve gloss and antistatic properties. They can also be used as process aids when producing individual ingredients that make up the paint, such as when grinding pigments or to improve pigment miscibility. It only been recently reported that fluorine components could be used in a paint formulation as a proprietary ingredient, so if present they may not be documented in the Safety Data Sheet. Both polymeric as non-polymeric PFAS may be used in organic coatings and finishes. 2.3.1 Non-polymeric PFAS in organic finishes Non-polymeric PFAS use identified in organic finishes is primarily used as a solvent. The primary constituents are Benzene, 1-chloro-4-(trifluoromethyl)- (CAS 98-56-6) and 1,1,1,2-Tetrafluoroethane (CAS 811-97-2). The purpose of organic solvents in a coating formulation is to dissolve the polymeric chains of the resin and other ingredients and produce a homogeneous liquid to allow acceptable application of the coating to the base material. The organic solvent will diffuse through and evaporate from the applied coating film after application and will not contribute to the film polymerization. In essence, solvents or thinners are added to the paint formulation to dissolve the solid ingredients of the paint formulation so they can be applied as a uniform aesthetically pleasing film that meets desired performance. The key functionalities of solvents in any coating or organic finish are to: Reduce and control coating viscosity so that the coating can be applied to the base material Control evaporation and diffusion rate to allow uniform and continuous film formation, free of film defects when the coating cures Contributes to wetting of the applied paint to the base material. Improved wetting means better adhesion. 30 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 l www.aia-aerospace.org 2.3.2 Polymeric PFAS in organic finishes Polymeric PFAS additives are incorporated into coating formulations that typically comprise significant amounts of components that do not contain fluorine. The purpose is to add or enhance properties imparted by fluoropolymers that are not necessarily present in these coatings. Additives may be in the form of an aqueous dispersion or by addition of polymeric PFAS particles to the coating matrix. Key properties given (or improved) by addition of polymeric PFAS to coatings generally include Reduction in wear, mar, and scratching Reduction in friction Improved release properties Water and oil repellency Specific coatings may be optimized for one or more of these or other properties. 2.3.3 Sub-uses and Key functionalities Organic finish coating formulation usually contains solvent, resin (binder), pigment, filler, and additives. When applied to the underlying substrate, they provide a continuous coating that prevents cracking and structure breakdown during the service due to exposure to various environmental conditions. Organic finishes are applied to various substrates including metals, plastics and composites. The first coating is typically the primer which can provide corrosion resistance to substrates, and to effect adhesion of subsequent finish coats where finish coating is required. Primers are usually selected as one of the elements of a finish system that can entail metal surface finishing (e.g. anodizing, conversion coating, plating, etc.), priming and application of a topcoat. The elements of a finish system vary based on the specific requirements and service environment of a part or component within an aerospace end product. Both polymeric and non-polymeric PFAS are present in organic coatings used in the A&D sector. In cooperation with IAEG, AIA has identified a number of sub-uses for this category. These are listed in Table 2 along with an indication of what type of PFAS they contain. Table 2 Uses ofPFAS in coatings Organic finish /coating Primer Topcoat Abrasion resistant coating Aluminized coating Conductive/RF coating Nonpolymeric PFAS x x x Polymeric PFAS x x x 31 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 l www.aia-aerospace.org Erosion resistant coating x x High temperature resistant coating x Temporary protective coating x Conformal coating x Fluorocarbon bonding preventative x Adhesion promoter for polysulfide and polythioether sealants x Hydrophobic coating x Primers. Primers are applied to various substrates including metals, plastics and composites. On metallic substrates they are formulated to provide corrosion resistance to substrates, and to effect adhesion of subsequent finish coats where finish coating is required. Primers are usually selected as one of the elements of a finish system, which generally includes metal surface finishing (e.g. anodizing, conversion coating, plating, etc.), priming and application of a topcoat. The elements of a finish system vary based on the specific requirements and service environment of a part or component within an aerospace end product. Key functionalities Corrosion resistance Adhesion Hardness Resistance to chemicals, fluids, humidity, impact, temperature Compatibility with other layers Topcoats. Topcoats are applied as the final finish process to complete the required environmental protection, and/or to provide the required visual characteristics, and/or provide other required special surface characteristics. Topcoating is not always required on permanently installed hidden or obscured items provided that the base material or primers are capable of furnishing the required environmental protection or special surface characteristics. Topcoats are usually selected in conjunction with the proper primer(s) to comprise a finish system. Key functionalities Adhesion Hardness Resistance to chemicals, fluids, humidity, temperature, UV light or other end-use environment Compatible with other layers Camouflage Chemical agent resistance Abrasion resistance 32 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 l www.aia-aerospace.org Abrasion Resistant Coating. This coating produces a very smooth surface with high flexibility, impact resistance and lubricity. In situations where the bearing loads are light, it is effective in minimizing the effects of rubbing. These coatings are applied only in the localized area where rubbing will occur in service, such as surfaces that mate against seals. Key functionalities Adhesion Abrasion resistance Aluminum Pigmented Coatings. Aluminum pigmented coatings are used on metallic fasteners. They are formulated to prevent galvanic corrosion and provide aerospace fasteners with lubrication properties. Key functionalities Corrosion resistance Appearance Conductive/RF Coating. Conductive coating consists of a base resin with conductive pigment and a curing agent. Also known as anti-static coatings, they are applied to nonconductive (for example, fiberglass and other plastics) surfaces. They are intended to facilitate the discharging and positive grounding of static electrical charges to the primary structure. Key functionalities Electrical conductivity/resistivity EMI/RF performance Flexibility Adhesion Compatibility with other layers Erosion Resistant Coating. A specialty coating or coating system used to protect surfaces of parts susceptible to rain and sand erosion or damage. Erosion resistant coatings are applied to leading edges of aircraft components flaps, stabilizers, radomes, and engine inlet nacelles, as well as surfaces like helicopter blades and wind turbine blades. Resin formulations of both polyurethane and fluoropolymers are commonly used to meet rain erosion performance criteria. Key functionalities Resistance to erosion by rain and sand Flexibility Impact resistance Weathering and moisture resistance Adhesion High Temperature Coating. Used in higher temperature environments without damage to the coating or underlying structure. Key functionalities 33 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 I I www.aia-aerospace.org  High temperature resistance Adhesion Temporary Protective Coating. Used to temporarily protect parts, components, structures etc. from environmental damage during manufacturing or maintenance. The coating is applied when the following step is not performed immediately and protection is required. Key functionalities Corrosion resistance Removability Conformal coating. Conformal coatings are insulating protective coatings, which conform to the configuration of the object coated. Used as a protective layer and encapsulant on in electronics on printed--wiring assemblies (PWAs). It is generally accomplished with an organic resin applied by dipping, brushing or spraying and is generally 0.003 to 0.01inches thick. Key functionalities Abrasion resistance, Electrical insulation Environmental isolation. Fluorocarbon bonding preventatives. Used to reduce friction and increase slippage between silicone rubber filler compounds and rotating aircraft engine components. Key functionalities Adhesion Compatibility to substrates Adhesion promoter for polysulfide sealants and polythioether sealants. The use of an adhesion promoter can significantly enhance the adhesion and bonding characteristics of polysulfide and polythioether aircraft sealant to a desired substrate. In addition, the use of adhesion promoter can sometimes compensate for surfaces that are difficult to access and may not have been adequately cleaned and prepared. This is especially applicable to repair purposes or when bonding to surfaces that are aged and have already been exposed to fuel and other fluids. Key functionalities Adhesion of sealants to substrates 34 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 l www.aia-aerospace.org Hydrophobic coating. Hydrophobic coatings are carbon-based coatings that utilize a high surface tension pigment, such as Teflon, to repel water from the surface. Fluorinated coatings also perform as hydrophobic coatings. The purpose of hydrophobic coatings is to cause water droplets that form on the surface to bead up and roll off similar to a freshly waxed car. Hydrophobic coatings are predominantly used as radome coatings, windshield coatings, or other surfaces where it is not desirable for water to easily wet. Key functionalities Hydrophobicity Adhesion 2.3.4 Status of R&D where alternatives not available We are not aware of active research and development activities to reformulate coatings using polymeric and non-polymeric PFAS. While AIA is not aware of active efforts to replace PFAS as solvent in existing already approved coatings, we are aware of efforts to proactively reformulate candidate coatings being developed for other aerospace projects and thus avoid the future use of PFAS solvents in these cases. It is still too early report on the success of these efforts. The specific substances being evaluated are proprietary to the formulators and cannot be disclosed at this stage. For the replacement of polymeric and non-polymeric PFAS, a coating must be fully evaluated through all maturity stages (e.g. development, qualification, validation, certification, industrialization) described in Section 1.7. OEMs will rely on formulators to propose PFAS-free candidates for testing. We question whether formulators would be able to efficiently develop and propose alternatives for all affected materials to be tested by OEMs, and whether OEMs would have the capacity to test many candidates. Under current circumstances, full evaluation and substitution of reformulated coatings may take a couple years in the best cases or much longer where multiple iterations are required. However, if the PFAS restriction becomes final, the number of reformulations that need to be evaluated concurrently will increase significantly, use up available testing capacity and result in increased backlogs and timelines. 2.3.5 Conclusion Non-polymeric PFAS used as a solvent would be expected to flash off during curing leaving an applied coating without PFAS. We do not have information on whether the applied coating would meet the proposed 25 part per billion concentration limit. If it did meet this limit, one option could be to apply coatings outside of the EU. In this scenario, production, maintenance and overhaul work would have to be done outside of the EU. The resulting non-use scenario would be similar to non-use scenarios described in aerospace and defense Authorisation review reports for chromate uses recently submitted by the Aerospace and Defence Reauthorisation consortium (ADCR). The use of non-polymeric PFAS in coatings is not addressed by any proposed or potential derogation in the restriction proposal. As such, the transition period would be 18 months after entry into force as currently proposed. This short transition period would not allow sufficient time to fully substitute these coatings. 35 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 l www.aia-aerospace.org The use polymeric PFAS in coatings in A&D applications are potentially covered in the restriction proposal under: 6.o [applications affecting the proper functioning related to the safety of transport vehicles, and affecting the safety of operators, passengers or goods until 13.5 years after EiF] Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 I I www.aia-aerospace.org 2.4 Seals Several high-performance fluoropolymers and fluoroelastomers such as FKM, FVMQ, FFKM and PTFE are used as material for O-rings, seals for valves and gaskets, face seals, hose liners, bearing seals, seals for electronic devices and nut seals etc. A large majority of these are used in the oil, fuel and air systems of aircraft engines. These materials have a long history of successful and safe use in commercial and military aircrafts. The use of these materials is governed by requirements set by industry specifications as well as airworthiness regulations. Fluoroelastomers, such as those meeting the requirements of SAE Aerospace specifications AMS7287 and AMS7257, are used to provide sealing of aircraft fluid systems such as aircraft engine oil and aircraft jet fuel. Fluoroplastics, such as those meeting the requirements of SAE Aerospace specification AMS3678, are used to support fluoroelastomer seals and to function as bearings in aircraft engine oil and aircraft jet fuel systems. These fluoroelastomers and fluoroplastics provide a combination of long-term compression set resistance at elevated temperatures and resistance to aircraft engine oils and aircraft jet fuels that are not available with other polymers. The temperatures experienced in some sealing locations in aircraft engines are well above 200C and sealing materials other than fluoroelastomers are inadequate under these conditions. 2.4.1 Key functionalities: Fluoropolymer based materials are vital in providing the following key functionalities to seals, O-rings and gaskets Friction and wear properties Mechanical strength Resistance to aircraft engine oils, jet fuels at elevated temperatures Resistance to other chemically aggressive fluids such as hydraulic fluids, de-icing agents, cleaners Electrical insulation Heat and flame resistance 2.4.2 Alternatives We are not aware of active research and development activities on non-fluoropolymer-based materials for A&D seal applications. Replacement materials, once developed by formulators must be fully evaluated through all maturity stages (e.g. development, qualification, validation, certification, industrialization) described in Section 1.7. They will require varying levels of component tests and engine tests to establish functionality & durability. These include, but are not limited to required component/system testing to show equivalent levels of performance for various parameters including: Thermal resistance Pressure resistance Geometry (stretch, squeeze, gland depth, seal profile, etc.) Material properties (hardness, set etc.) Material compatibility (fluids, metals, electrical resistance, etc.) 37 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 l www.aia-aerospace.org Current designs use seal/hose geometries established based on operational experience with fluoropolymers and new/alternative materials may also require updated or new geometric design standards. Potential alternatives to aerospace seal materials made of perfluoroelastomers have been presented in a report compiled by Dupont (EPPA, 'Submission documentfor public consultation ofpotential restriction of the per- and polyfluoroalkyl substances (PFAS) related to precision polymeric parts and shapes used in high performance industrial operating environments'). Data presented in the report show that nonfluoropolymer-based materials such as Hydrogenated Nitrile Butadiene Rubber (HNBR) and Silicone (VMQ), while comparable in some properties, are not able to offer the complete set of characteristics provided by fluoropolymers. Similarly, for wear strips, molded shapes and seals made of fluoropolymers a number of alternatives including bronze, steel, polypropylene, polyvinyl chloride (PVC), polyether sulfone and others are shown to fall short in their ability to meet all requirements. Other polymers which have been used in aircraft fuel systems in the distant past, such as nitrile polymers, do not have the long-term, high temperature compression set resistance required by today's high efficiency aircraft engines. Substitution of fluoroelastomers with these inferior polymers would result in inefficient aircraft engines with poor durability and increased maintenance. 2.4.3 Conclusions and Adequacy of proposed derogation The use of fluoropolymers as material for seals in A&D applications are potentially covered in the restriction proposal under: 6.o [applications affecting the proper functioning related to the safety of transport vehicles, and affecting the safety of operators, passengers or goods until 13.5 years after EiF]. In addition to the unmatched properties of the fluoropolymers, the number and variety of applications that employ fluoropolymers will make the identification and qualification of alternatives an immense task, making an extended duration derogation absolutely essential. As mentioned above, there are no alternatives currently available and the testing required for any new material will be extensive. 38 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 l www.aia-aerospace.org 2.5 Wires, Cables and Optical Fibers Wires, cables and optical fibers are extensively used in aircrafts, satellites, radars and other A&D systems. They serve to provide a network of reliable electricity and signal transmission to control communications; safety and mission critical systems including flight controls. A single aircraft, satellite, or vehicle will have numerous cables and cable assemblies, each with unique performance requirements based on its specific use in a complex system. Cables and Cable Assemblies used in A&D applications must operate reliably over a long product life cycle that can reach beyond 30 years. Different types of polymeric PFAS such as PTFE, FEP and PFA are used in aerospace wire insulation applications. In most cases their use is required by standards due to their superior performance for mechanical strength, electrical insulation, heat and flame resistance and chemical resistance. Fluoroplastics, such as those meeting the requirements of SAE Aerospace specifications AS23053/11, AS23053/12 and AS23053/13, are used as heat-shrinkable tubing to provide mechanical protection and electrical insulation for electrical wiring in aircraft electrical systems. These fluoroplastics provide a combination of mechanical strength, electrical insulation, heat and flame resistance, and resistance to aggressive aircraft fluids that are not available with other polymers. Fluoroplastic electrical insulation, such as that used to meet the requirements of SAE Aerospace specification AS22759/11, is used to coat electrical wiring to provide electrical insulation in aircraft electrical systems. 2.5.1 Key functionalities Key performance requirements for wires, cables and optical fibers in A&D include: Thermal resistance over a wide range of operating temperatures Cables experience a wide range of operating temperatures from extreme conditions in varied climates, to low temperature at high elevation during flight and the extremes of space. This may range from temperatures below -100 C for some space applications to greater than 150 C. Dielectric constant (Er) Dielectric constant is an important material characteristic which relates to the ability of the material to store electrical energy in an electrical field. Low dielectric constant values are necessary for high frequency or power applications to minimize electric power loss, enabling precise, consistent, and efficient signal transmission. Chemical resistance The material must perform its function in harsh conditions and provide chemical resistance to oils, aircraft fluids, fuels, and other chemical substances. Mechanical strength and flexibility The wires and cable materials must be highly durable and withstand frequent/rapid flexing, torsion, and pulling without compromising electrical performance under demanding environments (e.g., extreme temperatures). Low coefficient of friction 39 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 l www.aia-aerospace.org The cable insulation and jacket layers must have a low coefficient of friction in order to decrease abrasion under continuous flexure and movement and during installation in aircraft and other systems. 2.5.2 Alternatives To operate in harsh and extreme conditions, cable applications need critical properties that only a small subset of potential materials can provide. Submissions to this consultation by various entities including W.L. Gore (# 6301), Dupont (# 4530), Amo Special cables (# 4479) present thorough analyses of the state of alternatives. Some of the alternative polymers and their shortcomings for A&D applications are outlined below: Polyimides -- lack of flexibility, high dielectric constant and stiffening under humidity Polyesters, Polyethylene, Polyurethanes - limited by maximum use temperatures and drop in performance over 80 C. Further they would require the addition of flame retardants most of which are of regulatory concern Silicones -- limited due to their high dielectric constant which leads to poor performance in signal transmission cables Polyvinyl chloride (PVC) -- lack of chemical resistance and low abrasion resistance 2.5.3 Conclusions and adequacy of proposed derogations From numerous comments made in response to the current consultation from electronics and semiconductor suppliers (and their representative trade associations), it is apparent how critical fluoroplastics are in developing and supporting A&D products, including aircraft, ground and test equipment and many other A&D products that depend on electricity for their proper functioning. As such, the US A&D industry is greatly concerned about the continued supply and cost of electronics products impacted by the final restriction. 40 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 l www.aia-aerospace.org 2.6 Refrigerants Refrigerants are used in refrigerators, chillers and freezers in aircraft galleys and in liquid cooling refrigeration units for cabin and cargo air conditioning. In defense applications, refrigerants are used in radars, operator shelters and defense vehicles. Fluorocarbon based refrigerant gasses have been in use in Aerospace and Defense equipment for over 10 years, principally as a replacement for Freon (HCFC-22 and R-22, typically) as a result of the ban on such substances more than a decade ago. These fluorocarbon-based refrigerants (HFC-134A, HFC-125) have proven to be functional in providing reliable and safe alternatives. In order to optimize the necessary thermal cycle however the integration of the fluorocarbon-based refrigerants involved significant redesign of the hardware. Further the Aerospace Industry has not yet identified a substitute for HFC134a that would satisfy the FAA and DoD certification criteria, and in particular a substitute with the low flammability properties of HFC-134a. Since 2010, our new products have been specifically designed and sized for HFC-134a and HFC-125 fluorocarbon based refrigerants being utilized. As weight/volume is critical within aircraft/spacecraft, this optimization is required to meet both size and purpose of use. 2.6.1 Key functionalities and Alternatives Fluorocarbon based refrigerants are critical to Aerospace and defense application: They must operate at Flying at 35,000 feet which exposes aircraft to -55C They must have low flammability properties Due to the closed environment of the applications, in the unlikely event of a leakage, the refrigerants must be non-toxic They must be thermally efficient to minimize system size and weight Most alternatives to Freon refrigerants currently available are materials developed to have lower global warming potential than the incumbents. However, these are still based on fluorinated chemicals (HFCs, HFOs or HFC/PFAS). Many of them have issues such as flammability even if they meet some performance requirements. For example, the thermal performance of R1234yf (hydrofluoroolefin; HFO) is similar to R134a, however, R1234yf's mildly flammable property makes it unsuited for use in aircraft environments. Another HFO based refrigerant, R513a is considered a "drop in" replacement (equivalent performance in terms of refrigeration capacity, pressures and temperatures) to R134a, however it has higher global warming potential. 2.6.2 Conclusions and adequacy of potential derogations Under the current restriction proposal, the use of refrigerants in A&D has potential derogations under the following: 5.q refrigerants in transport refrigeration other than in marine applications until 6.5 years after EiF; and 5.dd [use as refrigerants and for mobile air conditioning in vehicles in military applications until 13.5 years after EiF]. In view of the discussion presented above, it is unlikely that these time periods will be sufficient to substitute PFAS containing refrigerants in A&D use and further technical readiness review with a scope for extension is requested. 41 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 I I www.aia-aerospace.org 2.7 Solvents, Cleaners The Aerospace and Defense industry depends on PFAS as solvents for many different uses, including as a general solvent in other chemical products (coatings, lubricants, cleaners, adhesives, water proofing agents), as well as direct use in specialized applications such as oxygen system cleaning and electronics precision cleaning. PFAS-containing cleaners have low surface tension enabling rapid penetration coupled with high solvency (Kb values >100) to remove oils, greases, silicone residues, polar materials and soils, dust, particulate and flux agents. They evaporate quickly and leave low to no residue. They contain low water content (hydrophobic) which is critical to aircraft and space components. They are nonflammable and can be used safely on heated surfaces. Further, PFAS-containing cleaners are safe to use on metals, ceramics, composites, and various plastics including but not limited to PVC, polycarbonates, nylons, phenolics and fluoropolymers such as PTFE and ETFE. PFAS solvents are used for cleaning equipment intended for use with either liquid or gaseous oxygen. Contaminants in oxygen-rich systems pose serious risks. Where used in industrial settings, oxygen cleaning eliminates fire or explosion danger due to flammable contaminants. They are often specified for use in space systems where low non-volatile residue requirements are mandated, along with oxygen compatibility and non-flammability. Hydrofluoroether-based oxygen system cleaners replace ozonedepleting substances (ODSs) and compounds with high global warming potential (GWP) previously used for that purpose. A & D. products with precision cleaning requirements include electronic equipment, including PWBs, switches, relays, etc.; Sensors; Actuators; fiber optic termini and fiber optic insert alignment sleeve holders. 2.7.1 Key functionalities and Alternatives In those uses, PFAS provides numerous beneficial properties, including low flammability/ acute toxicity (vs. some other potential alternatives), rapid and complete evaporation, non-reactivity/ compatibility with other materials, low moisture absorbency, excellent solvation/ surfactant properties such as low surface tension thermal stability. Specific uses include uses in coatings, desmutting, degreasing, glass surface treatments for aircraft cockpits and in 3D printing release agents and in primary lithium batteries. PFAS solvents are also essential for the performance of critical fluoropolymer resins. Expanding on the dependence of our industry to critical uses in the A&D value chain, it is apparent that many parts and assemblies that the industry relies on for consistently producing effective, safe, reliable and supportable products will be severely (if not completely) impacted by a restriction on PFAS solvents. 42 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 l www.aia-aerospace.org Solvents historically used for oxygen tube cleaning have been phased out and are no longer available. Trichloroethylene based vapor degreasing was prominent among these. TCE is now listed on Annex XIV and subject to Authorisation. Efforts to qualify aqueous cleaners met with limited success. Ultimately PFAS based cleaners using constituents such as Pentane, 1,1,1,2,2,3,4,5,5,5-decafluoro- (CAS # 13849542-8), Butane, 1,1,1,2,2,3,3,4,4-nonafluoro-4-methoxy- (CAS # 163702-07-6), 2[Difluoro(methoxy)methyl]-1,1,1,2,3,3,3-heptafluoropropane - (CAS # 163702-08-7) have been the most successful replacements. 2.7.2 Conclusions AIA member companies and companies in their supply chains operating the EU as well as their customers, including commercial operators and ministries of defense (MODs), will all require the use of continued use of PFAS-based solvent cleaners until alternatives are developed and qualified that meet all performance requirements. At this time, we cannot say with certainty what alternatives would be pursued nor how long this endeavor would take from start to finish. Nor can we say with certainty that two of the proposed derogations (5.k: industrial precision cleaning fluids until 13.5 years after EiF; and 5.1: cleaning fluids for use in oxygen-enriched environments until 13.5 years after EiF) in the restriction report would allow enough time to develop, qualify, validate, certify and industrialize replacements for all applications. Both of these derogations are clearly applicable to A&D, but is also unclear that these two derogations would cover all of our required uses. 43 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 l www.aia-aerospace.org 2.8 Composite Processing Applications Composites in A&D applications usually refers to layered combinations of carbon fiber or fiberglass in a plastic resin, combining properties of each material. They are broadly used aerospace applications because of their ability to be formed into complex shapes, lighter weight, exceptional strength, durability, fatigue properties and reduced corrosion potential. In aircraft applications composites are used for fuselage, radomes, landing gear doors, strut-forward and aft fairing, outboard flap, trailing edge panels, fin torque box, rudder, elevator, floor beams, flaps, ailerons, inboard and outboard spoilers, engine cowling, central torsion box, tail cone, vertical and horizontal stabilizers, and more. In aerospace composite applications fluoropolymers are important both in processing and sometimes as a functional layer incorporated into composites. In order for composite materials to maintain repeatable processes, careful evaluation and consideration of material types are used. Fluoropolymer based composite release films (or parting films) allow for removal of composite parts from other media used in the curing process. The films also have heat resistance, good elongation and strength and provide a low friction surface. Fluoropolymer films are also used extensively for production of composite parts prior to cure. The lubricity of the film surface is critical in the ability to manufacture said complex shapes with extremely tight tolerances that enable the high level of performance for A&D advanced composite structures. Fluoropolymers are also used extensively in automated equipment used for composite part production. With high speed processing and heated operations, it is critical to the functionality of these machines that the extremely sticky resins typical of uncured composite materials do not stick to contact surfaces within the equipment. Fluoropolymers are ideal for this type of equipment and is used extensively throughout the industry in this way. Example uses are: Location and positioning of materials during the layup of uncured parts. These are commonly referred to as shop aids. Teflon backed tapes for maintaining placement of composite part constituents like honeycomb core Protective film on table surfaces (for example) for manual manipulation of uncured material Rollers, tension bars, guide rails and other components for automated equipment such as Automated Fiber Placement (AFP) and Contoured Tape Laying Machine (CTLM) Protective film for material after kitting, moving between work stations Utilization as a slip plane for complex part assembly Part quality aid during cure such as breather 2.8.1 Key functionalities: Composite parts must be carefully manufactured, evaluated, & tested to ascertain that the materials repeatably demonstrate critical performance properties as designed. These designs are a key aspect of how composite material achieve the benefits for lighter weight, higher performing structure. Not only 44 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 l www.aia-aerospace.org does this result in more cost-efficient structure but also A&D platforms with lower environmental impacts due to reduced fuel burn, greater payload capability per trip. Fluoropolymers like PTFE and FEP are used extensively in these highly controlled and detailed manufacturing processes. These materials are chosen for many reasons including: Low adhesion for maximum releasability (lubricity) -resin must not stick to these shop aids as loss of resin can result in degradation of material properties. Modern A&D composite material system are typically net resin systems Minimum transfer of residue that can result in unacceptable adhesion, mechanical strength or fatigue performance of subsequent layers (e.g. composite, primer/paint, etc.) Ease of handling and ability to resist wrinkles, tears or other discrepancies such as delamination, distortion, inclusions etc. that can degrade part quality. Strength and durability of the film or machine components to maintain shop operations. 2.8.2 Alternatives For the use of fluorinated systems as shop aids, one AIA member company has undergone an extensive survey of usage and potential alternative materials as the result of a contamination investigation. Through that investigation, implementation of alternatives like polyethylene (PE) was investigated for placement of preforms, use as a slip plain material, etc. While some applications could make the switch, it was found that there were other instances where the engineering tolerances were such that only the higher lubricity and strength to thickness offered by PTFE was capable of manufacturing the part in question without inducing quality defects. Other shop aids such as the tapes and breathers have also been difficult to find replacements as many of the alternatives present on the market pose significant risk to part contamination (silicone coated breathers for example or acrylic backed tapes). All contact materials that are used in the production of composite parts go through an extensive testing program to ensure that they do not pose a risk to the resulting structural laminate. If they are used with multiple composite types (e.g. epoxy, bismaleimide (BMI), cyanate ester), they must be screened against each unique resin chemistry and process type to ensure compatibility. This often results in an iterative effort to find a specific shop aid that functions with the material system and part configuration. For application of fluorinated components in automated equipment, the industry offers some alternatives such as silicone rubber. However, this material does not offer the same wear resistance as its fluorinated counterparts. This material has a much higher risk of contamination to the composite laminate, especially as the components wear over time and usage. Processes and safeguards must be in place to ensure that this does not occur as it can cause structural failure due to silicone transfer to the composite material. This transfer is not detectible with standard NDI techniques or other quality inspection processes. The fluorinated components not only have significantly less contamination risk but also have better wear life typically. Metallic or ceramic components are also sometimes utilized. However, the most common version of these are actually ones that are embedded with PTFE coatings to help with resin release and cleanliness. The ability to find a substitute or alternative approach around PFAS impacted composite production is very dependent on the structure in question as well as the production environment. The use of PVF as a 45 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 I I www.aia-aerospace.org barrier film on critical structure such as engines helps to protect critical components from water ingress during flight. Multiple efforts over the last 20 years have been undertaken to find an alternative to this material due to cost and sourcing concerns. However, other polymeric systems that could be co-cured with the underlying epoxy substrate did not prove to have either the environmental resistance (was not a good barrier film) or was not resistant enough to the chemical environment found around propulsion systems for life of the airplane usage. 2.8.3 Conclusions As described above, fluoropolymers provide essential characteristics and functionality in the production of composites in the A&D sector and cannot be easily substituted. A&D companies are not aware of materials with similar properties to fluoropolymers that could fill the roles described here. If potential candidate materials were identified they would need to be fully tested and qualified before being put into use. In fact, since such a change in production method could potentially affect the quality of parts produced and hence the overall design certification of the aircraft, the effort needed to substitute them would need to follow the same process as is used to substitute as described in section 1.7. The clock on the substitution timeline could start only after such materials are identified. Companies in the A&D sector are confident that the potential derogation 6.o (which allows for applications of fluoropolymers affecting the proper functioning related to the safety of transport vehicles) would be applicable in this situation, as the required composite parts could not be produced without them. However, this potential derogation would expire after 13.5 years, which, given the current state of unknown potential alternatives, would require some (perhaps all) EU composite processing applications to cease (and likely be moved out of the EU). 46 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 l www.aia-aerospace.org Appendix A: GCCA White Paper AIA understands that the link to the AIA white paper on the GCCA website is currently not functioning. The text of the white paper titled "Aerospace & Defence Qualification Process Impacts on Ability to Substitute Cr(VI) Substances" is reproduced here for reference. Aerospace & Defence Qualification Process Impacts on Ability to Substitute Cr(VI) Substances Aerospace and Defence (A&D) products operate and carry people in extreme environments over extended timeframes, while having to fulfil extremely challenging technical, reliability, and safety requirements. To ensure the safety and reliability of aerospace products, comprehensive airworthiness regulations have been in place globally for decades. These regulations require a systematic and rigorous framework to be in place to qualify all materials and processes to meet stringent safety requirements that are subject to independent certification and approval through, EASA and other agencies requirements. Air, ground and sea-based defence systems, and also space systems, are subject to similar rigorous qualification requirements. Changes to A&D hardware offer unique challenges that are not seen in other industries. The A&D companies that design and integrate the products (e.g. aircraft, engines, radar systems, missiles), are each responsible for their own product qualification, validation and certification, according to airworthiness regulations or defence/space customer requirements. Within a single A&D company, even seemingly 'similar' components or hardware used in different systems/models have unique design parameters and performance requirements, driven by the system-level requirements of the final delivered product. A&D products cannot be placed on the market without going through this demanding process irrespective of any REACH legislation. The same rigorous process is in place to approve materials used for the repair and maintenance of these products. Figure 1 illustrates the process required in the A&D industry when substituting a material. 47 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 l www.aia-aerospace.org Testing failure paths` Development QUahludilOn Test plan tratitian and approval Component/ ovine / AIM iodine a approval of tact musks Drawins release Manual creation midden tJr Certification Industrialization Could take up to 7 years or more Could take up to 15 years Could take up to 10 years Formulators Manufacturing Supply Chain A&D Companies, multiple departments Regulators Failure at any stage can take you back to the beginning of the process with a new potential alternative Airline and Maintenance, Repair and Overhaul Companies Figure 1: Illustration of the development, qualification, validation, certification and industrialisation process required in the aerospace industry Whilst a formulator may introduce an alternative into their products, there are many discrete activities required to introduce an alternative candidate into A&D hardware. The testing and qualification criteria is dictated with due regard to the design and performance requirements of each component and system. An example suite of tests for primers may include enhanced corrosion, fatigue, chemical resistance, erosion, repair and manufacturing trials, engine and/or flight tests. Once a candidate technology has reached a sufficient level of maturity, then integration into products is permitted. Industrialisation is an extensive step-by-step methodology followed in order to implement a qualified material or process throughout the manufacturing, supply chain and maintenance operations, leading to the final certification of the A&D product. This includes re-negotiation with suppliers, investment in process implementation and final audit in order to qualify the processor to the qualified process. An individual component may become part of multiple subsystems and systems, each imposing its own design requirements and challenges. Thus, successful substitution for one component in a given subsystem does not imply that it is suitable for use in a different subsystem. Each individual subsystem and system must be assessed and validated independently. Formulators are responsible for developing and performing the preliminary assessment of any candidate alternative's viability. However, only the original design owner can determine when a candidate alternative is fully qualified and/or validated and therefore meets both airworthiness and comparable performance requirements for each of their A&D applications independently. The A&D industry has long recognized the risks associated with Cr(VI) and the necessity of implementing the use of alternatives. Significant efforts have been expended by the A&D industry over several decades to develop and implement alternatives. A&D companies have rigorous processes in place requiring extensive documentation, reviews, and approvals to justify use of Cr(VI) in new designs or changes to existing designs. Once a new validated, certified and approved alternative is incorporated into a design, adherence to the new design becomes a contractual and regulatory requirement. 48 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 I I www.aia-aerospace.org Despite these efforts, there remain many applications for which no suitable alternative can be implemented. Recognizing that there are many different uses of Cr (VI) and that each must be assessed individually, to date there is no universal replacement for any of these coatings and surface treatments for A&D uses. For many A&D products it may not be feasible to make certain changes due to the complexity of ensuring that no negative impacts are introduced into proven designs. The complex relationship between each component and its performance requirements within its own unique design parameters requires certification of each substitution individually (see Figure 2). Qualification in one particular application does not guarantee that use in another application is qualified. Every application must be individually assessed to determine that requirements are met. This process must be independently replicated across all A&D products by each A&D company. A&D products (e.g. a specific aircraft model) may be in service for 30-50 years (even longer in defense uses), requiring maintenance, repair and spare parts over their entire service lives. Any changes to these parts or processes must be fully validated and certified to ensure safety and performance are not compromised. ComponentsA 4 K Subsystems L 4 P Systems G 4 R Subsystem P "rdi Subsystem N Subsy_ stem i t :Ail subsystem o \ <D 'A fi 'njI Subsystem Subsystem P Subsystem N Subsystem 0 System R [ Subsystem L ) Subsystem !A System Componenttesting 2=1:mkm=mk-ac=mk Figure 2: Systems assessment and validation overview The industry was diligently pursuing alternatives prior the passage of the REACH regulation, and will continue to do so regardless of the details of any particular Authorisation decisions. 49 Aerospace Industries Association of America, Inc. 1000 Wilson Boulevard, Suite 1700 I Arlington, VA 22209-3928 l www.aia-aerospace.org